This Policy applies to Personal Information that Co-op collects through the Site(s) and when users contact Co-op.

Please read this Policy and the Terms of Use carefully.  By using Co-op’s Site(s), users are agreeing that they understand the terms of this Policy and the Terms of Use.

Co-op collects information when users provide it to Co-op.  Co-op also collects information about users through automated technologies on Co-op’s Site(s) and from third parties.  When Co-op links information to users that was collected through automated technology, Co-op treats that information as Personal Information.

A.    Information that users provide

Co-op collects Personal Information from users when users provide it.  For example, a user might provide Co-op with their Personal Information when they e-mail Co-op, telephone Co-op, sign up for an e-mail newsletter, submit comments, submit a resume or job application, participate in a promotion, survey or other feature of the Site(s), communicate or interact with Co-op through Co-op’s Site(s) or a social media site such as Facebook or Twitter.

If users do not want their Personal Information collected by Co-op, they should not submit it.

B.    Automated information and cookies

When users visit or interact with the Site(s), Co-op or Service Providers may use technologies that automatically collect information about how a user accesses, navigates and leaves the Co-op Site(s).  For example, Co-op or its Service Providers will collect information on what other website the user came to before visiting the Site(s), what browser type and operating system the user is using, the Internet protocol (IP) address the user is accessing the Site(s) from, the pages the user is navigating through and what website the user goes to after visiting Co-op’s Site(s).  In general, Co-op does not associate this type of information with other Personal Information about a user except in the case of an investigation into Co-op’s website security.

Co-op’s Site(s) may also use cookies.  Cookies are data files that are placed on the device a user utilizes to access Co-op’s Site(s).  These cookies are used to remember a user’s language preference and to facilitate a user’s navigation of Co-op’s Site(s).  Co-op may also use technologies such as web beacon technologies (sometimes referred to as pixel tags and clear GIFs).  These are transparent images that provide Co-op or its Service Providers with information about whether a page or e-mail has been viewed or forwarded and may communicate with servers of Co-op or its Service Providers in order to obtain images and other content and to relay information about the IP address being used to access Co-op’s Site(s) and information about a user’s browser.  Co-op may use cookies and web beacons to present advertisements to users that Co-op thinks may be of interest to a user.  Although the information Co-op collects through cookies and web beacons is typically not combined with information that would identify a user, there is the potential for this information to be associated with a user and, therefore, Co-op treats it as Personal Information.

Users should reference Cookies, advertising and how to opt-out [below] for more information on how Co-op uses cookies and web beacons and how users may opt-out.

The Site(s) are not directed to or suitable for children under 13.  Co-op does not knowingly collect Personal Information from anyone under 13 years of age.  If Co-op becomes aware that Co-op has unknowingly collected personally identifiable information from a child under the age of 13, Co-op will delete this information from Co-op’s records or, if that is not reasonable, Co-op will take reasonable available steps to de-identify the information.  Children who are over the age of 13 but under the age of majority in the jurisdiction in which they reside should not provide Co-op with Personal Information without their parent’s or guardian’s consent.

Co-op uses information collected from a user for business purposes.  For example, Co-op uses Personal Information:

• to respond to a user’s inquiries and provide a user with information, such as information on Retail Membership;
• to register a user for Co-op programs;
• to assist in optimizing a user’s experience with Co-op by collecting information regarding a user’s product preferences and purchasing history;
• to assist with any consumer safety notifications;
• to monitor product quality and to communicate with users about the quality of Co-op’s products;
• to provide users with newsletters and other advertising;
• to provide users with features on Co-op’s Site(s), such as community forums or interactive features; and
• to identify participants in contests and promotions.

If a user submits a job application or resume to Co-op, Co-op will collect the information that a user provides to Co-op to determine whether the user would be a suitable candidate for a job at Co-op.  Co-op may retain this information in Co-op’s files for a reasonable period of time after a user submits it in the event a future position becomes available, unless a user requests Co-op not to do so.

In addition, Co-op uses information in order to learn about Co-op’s customers in order to improve Co-op’s Site(s) and to develop new products and services.  For example, Co-op uses information received from automated technologies to determine how many visitors visit areas of Co-op’s Site(s), how long they remain on Co-op’s Site(s), and whether they use the hyperlinks Co-op provides.  Users may also reference Cookies, advertising and how to opt-out [below] for more information on how Co-op uses cookies and web beacons and how users may opt-out.

Users consent to the collection, storage and use of their Personal Information when they provide it to Co-op or they provide it to a third party and give the third party permission to send that information to Co-op.  The purposes for the collection of Personal Information that users provide to Co-op are usually stated or implicit in the context in which a user gives it to Co-op or a third party acting on Co-op’s behalf.  If Co-op wants to make additional uses of a user’s Personal Information, Co-op will ask the user for their express consent.  For example, if a user provides Co-op with their e-mail address so that Co-op can provide the user with a newsletter, Co-op obtains the user’s implied consent to use the user’s e-mail address for providing the user with Co-op’s newsletters.  If a user provides Co-op with their e-mail address when they make an inquiry, Co-op obtains their implied consent to use it for the purposes of responding to their inquiry.  Co-op may ask the user for their opt-in consent to use their e-mail for other purposes.

Co-op uses opt-out consent for cookies and web beacons and other automated information.  If a user does not want Co-op to collect or use this information, they should not visit Co-op’s Site(s).  In addition, a user may opt-out by using browser settings that will not accept cookies or setting their e-mail application to not download images.  In addition, users may opt-out of certain on-line advertising.  Users may reference Cookies, advertising and how to opt-out [below] for more information.

Co-op may share information that it collects about users in the following circumstances:

A.    Service Providers providing services to Co-op or on Co-op’s behalf

Service Providers provide services to Co-op and may provide services to users on Co-op’s behalf.  Co-op may share a user’s Personal Information or information that Co-op has collected through automated means on Co-op’s Site(s) with Co-op’s Service Providers.  For example, Co-op’s Service Providers may host Co-op’s Site(s), analyze data collected from Co-op’s Site(s), provide customer service on Co-op’s behalf, provide and manage social media sites on Co-op’s behalf, administer Co-op’s promotions, provide marketing or promotional assistance, post Co-op’s advertisements, and collect user’s feedback on Co-op’s Site(s) and advertisements. Co-op is a member of Federated Co-operatives Limited (“FCL”) and will from time to time disclose your personal information to FCL to allow it to process your personal information for research and marketing purposes.  FCL may need to disclose your personal information to third parties with whom it has contract agreements in place for the purposes of managing your personal information such as data collection and processing companies.  The Co-op provides FCL with only that information which is necessary to perform the required services.  Other than the disclosure of your personal information to FCL for the aforementioned purposes, the Co-op will not disclose your personal information to any organization without your consent, except where permitted or required by law.

B.    Aggregated or de-identified information

FCL does not sell or rent user’s Personal Information to third parties.  However, FCL may share information in aggregated statistics and de-identified form with third parties without a user’s consent.

C.    When a user specifically agrees to Co-op sharing their information

In some situations, a user may specifically agree to Co-op sharing their information.  For example, if a user provides Co-op with their contact information, e-mail address, Facebook account, or Twitter account for the purposes of signing up for information or marketing offers from a third party, Co-op may share their Personal Information for that purpose.  A user’s Personal Information will be subject to the privacy policy and business practices of Co-op’s third party.

D.    Business Mergers or Acquisitions

Co-op may sell or purchase assets.  If another entity acquires Co-op, or all or a portion of Co-op’s assets, information that Co-op collected from users may be shared with that entity.  The information will be shared for the purpose of that entity considering whether to enter into the transaction and also to complete the transaction.  Should such a sale or transfer occur, Co-op will use reasonable efforts to direct that entity to use the user’s information in a manner that is consistent with this Policy and the purposes for which the information was originally collected.  Also, if any bankruptcy or reorganization proceeding is brought by or against Co-op, a user’s information may be considered an asset of Co-op’s and as such may be sold or transferred to third parties in those proceedings.

E.    Other legally required or permitted disclosures

Co-op may also disclose the Personal Information of users in the following circumstances: (a) if such disclosure is necessary for Co-op to receive legal advice; (b) to collect a debt from a user; (c) if Co-op is required to disclose a user’s Personal Information in order to comply with any legal obligation or the decision of a judicial authority; (d) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation; (e) if Co-op has reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law; or (f) where Co-op is otherwise permitted to do so by applicable law.

Co-op retains the Personal Information of users to fulfill the purposes for which it was collected.  Co-op maintains and also requires its Service Providers to maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of Personal Information.  For example, Co-op uses password protection where appropriate and limits access to staff, employees, and Service Providers who need to have access to it for the purposes for which it was collected and who have acknowledged their obligations to protect the Personal Information.  When Co-op transfers Personal Information, Co-op uses encryption where appropriate. Co-op cannot, however, guarantee the security of Personal Information held or transferred by it.

If a user is located in Canada, they should be aware that information Co-op collects may be transferred to and processed in the United States and other countries in which Co-op Service Providers have operations.  Although Co-op requires Personal Information being handled by its Service Providers to be protected to comparable levels of security as would be required in Canada, the privacy laws in these other jurisdictions may not be as comprehensive as or equivalent to those in Canada.

Co-op’s Site(s) may link or direct a user to other websites, services or external content resources which are outside of Co-op’s control.  Once a user has left Co-op’s Site(s), Co-op cannot safeguard and is not responsible for the protection and privacy of any Personal Information which a user provides on other websites.  These other websites may send their own cookies to a user’s device and may independently collect data or solicit Personal Information.  Please review the applicable terms of use and privacy policies for those other websites.

Co-op, or its third-party advertising Service Providers, may use cookies, web beacons and other technologies.  Co-op uses these technologies to gather statistics about a user’s use of Co-op’s Site(s), whether the user has opened e-mail advertising from Co-op and for other marketing purposes, including delivering advertising to the user.

If a user would prefer not to accept cookies, most browsers will allow the user to: (i) change their browser settings to notify the user when they receive a cookie, which lets the user choose whether or not to accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject any cookies.  A user may also set their e-mail options to prevent the automatic downloading of images that may contain technologies that would allow Co-op to know whether the user has accessed Co-op’s e-mail and performed certain functions with it.

If a user wishes to verify, correct, or update any of their Personal Information collected by Co-op or its Service Providers acting on Co-op’s behalf and that FCL has received from these Service Providers, the user may do so by contacting Co-op by visiting the Contact Your Co-op page.

Co-op may request Personal Information from the user in order to authenticate the user’s identity before providing the user with access to their Personal Information or complying with any request to correct or update their Personal Information.

Please also note that in some cases Co-op may legally deny the user access to the information that Co-op has collected about the user.  For example, this may occur where the information is subject to solicitor-client privilege or consists of references to other persons or proprietary information that cannot be severed.

Co-op may routinely delete certain records that contain Personal Information in accordance with its’ record-keeping practices.  Although Co-op will make efforts to comply with any request that a user may make to destroy Personal Information about the user that is not otherwise required by Co-op to fulfill legal requirements or to protect Co-op’s interests, the user should be aware that it is not always possible to completely remove or delete all of the user’s Personal Information from Co-op’s databases without some residual copies of data because of backups, archival systems and other reasons.  Co-op will not, however, continue to use a user’s Personal Information for active purposes once the user has requested Co-op not to do so.

If a user has any questions or comments about this Policy, Co-op may be contacted by visiting the Contact Your Co-op page.

This policy was last updated on June 25, 2014.